FAA/Aviation Industry Meeting Minutes from
Ops Spec Working Group (OSWG) 2012-03

July  17th and 18th , 2012

Tuesday July 17th, 2012 - 9:00 am - noon Domestic Industry Pre-meeting

Tuesday, July 17th : 1:00 PM – 5:00 PM   INDUSTRY-FAA Session

Wednesday, July 18th : 9:00 AM – NOON   INDUSTRY- FAA Session

Hosted by FAA

Heritage Center (Navy Memorial)

Washington, DC



Future Meeting Schedule:

Domestic, Joint, and International Sessions

October 16-17, 2012

OSWG 2012-04

Washington, D.C.

Domestic Sessions

February 5-6, 2012

OSWG 2013-01

Washington, D.C.

Domestic, Joint, and International Sessions

May 7-8, 2013

OSWG 2013- 02

Washington, D.C.

Domestic Sessions

August 6-7, 2013

OSWG 2013-03

Washington, D.C.

Domestic, Joint, and International Sessions

November 5-6, 2013

OSWG 2013-04

Washington, D.C.




U.S. Domestic (Part 121, and 135)

Casey Seabright, Delta, Industry Chair

Rich Yuknavich, American Airlines, Industry Vice Chair

Bob Davis, AFS-260, FAA Chair


International (Part 129)

Brian Miles, Emirates, Industry Chair

David Oliver, Qantas Airways Limited, Industry Vice Chair

Danuta Pronczuk, AFS-52, FAA Chair

Mike Frank, AFS-52, FAA Vice Chair


Transportation Division, AFS-200, Manager: Les Smith

AFS International Programs and Policy Division Manager: John Barbagallo


IFO/IFU/SEA FSDO Representatives to the Part 129 OSWG :   David Krueger (DFW IFO), Dave Henthorn and Bryan Ashley (LAX IFO), Rolfe Dinwoodie (ROC and ALB IFU), Herbert H. Herzog III, W. Scott Schweizer and Patrick Crowley (ANC IFU), J.J. (MIA IFO), Robert L. Jaffe (NY IFO), and David May (SEA FSDO)


IATA Representative: Jeffrey T. Miller


Meeting Location :   Heritage Center (Navy Memorial) 701 Pennsylvania Avenue, NW

      Washington, DC 2004                                       (Phone: 202-737-2300)



Table of Contents


(Blue font indicates linked text; page headers link back to TOC page)

Day 1                 AFTERNOON SESSION                 17 July 12






Agenda Topic or Operations Specification Title





AFS-200 Manager Opening Remarks




Convening Chairperson’s Remarks




Special Pilot-in-command Qualification Airports (KMMH)




Special Pilot-in-command Qualification Airports (BAIR)




Special Non 14 CFR Part 97 Instrument Approach or Departure Procedures




IFR Approach Procedures Using Vertical Navigation (VNAV)




Issuance and Applicability




Part 97 NDB, NDB/DME, VOR, and VOR/DME Instrument Approach Procedures Using Substitute Means of Navigation





Class II Navigation





Class II Navigation




North Atlantic Operations with Two-Engine Airplanes Under Part 121




IFR RNAV 1 Departure Procedures (DP) and Standard Terminal Arrivals (STAR)




Alternate Airport IFR Weather Minimums




Special Airport Authorizations, Provisions Limitations




Aircraft Network Security Program (ANSP)




Parts Pool Agreement Authorization




Special Flight Permit with Continuous Authorization to Conduct Ferry Flights




Minimum Equipment List (MEL) Authorizations




WebOPSS Update




CAST Safety Enhancements




ICAO Registry of AOCs




EASA Third Country Operators




Electronic Record Keeping Systems




Aviation Weather




Fuel Reserves for Flag and Supplemental Operations




Aircraft Interchange Agreement for Part 121





Airplane Authorization/Operational Requirements Airplane Design

Group VI (ADG-VI) Airplanes.




Special Limitations and Provisions for Instrument Approach Procedures and IFR Landing Minimums




Terminal Instrument Procedures




Land and Hold Short Operations (LAHSO)




Utilization of a Weather Support for Deicing Decision Making (WSDDM) System




Terminal Visual Flight Rules, Limitations and Provisions




Closing Remarks







1.       AFS-200 New Manager Opening Remarks

Bob Davis introduced the newly appointed AFS-200 Manager of Flight Standards Service - Air Transportation Division. Les previously managed the Next Gen Branch. Les expressed his appreciation for industry participation and continued presence at Washington meeting venue.

      Les mentioned that his new branch will be publishing three Advisory Circulars covering Crew and Fatigue Risk Management in the coming weeks. Les expressed the hope that Next Gen Initiatives were paying dividends on the industry investments in equipment and Training for RNAV/PNP capability. Les admitted that there is some uncertainty about the direction and pace of progress in the Next Gen area, but expressed a belief that technological developments will result in safer and more efficient air travel.

        Les opened up the meeting for questions from the group participants.

Rich Yuknavich, Industry Vice Chairperson praised the progress that has been made on several issues such as expansion of lower minimums ILS approaches. Rich then contrasted that with the seemingly slow pace of progress on resolution of the issues surrounding the use of GPS approaches for alternate airport minimums.

Les promised to become conversant on the issue especially the ongoing MITRE study.

        Les announced that Bob Davis is now AFS-200 acting assistant manager. Congratulations to Bob!

Industry representatives are expecting commensurate elevation from their respective companies.



2.       Convening Chairperson’s Remarks

Bob Davis, FAA Chairperson (and AFS-200 Assistant Manager least you forgot) thanked the Navy Memorial staff for their support. Bob also repeated thanks to all the industry and FAA out-of-towners for traveling to D.C. He mentioned that having the meetings permanently in D.C. usually permits more FAA headquarters representation. Bob recognized the increased expense to carriers and CMO/FSDO members, and hoped that participants tried to save hotel expenses by staying in Crystal City or Alexandria.

Roster and Roll Call/Introductions:

Rich Yuknavich, Industry Vice Chairperson: A copy of this meeting’s Roster will be sent in a separate electronic file to all those on the OSWG email distribution list. If you did not attend and wish to be on the roster, please contact the applicable FAA or industry chairperson. (Default: Rich.Yuknavich@aa.com).



3a. C050: Special Pilot-in-command Qualification Airports (KMMH)


FAA Lead: Bob Davis, AFS-260 

Industry Lead: Steve Bush, Horizon Airlines

Issue Statement:

Mammoth Yosemite; (KMMH), Mammoth Lakes Calif., an airport with scheduled 121 passenger service, located in the Eastern Sierra Nevada Mountains, has many of the attributes that would qualify it as a Special Pilot-in-Command Qualification airport; however, this airport is not included on the list maintained by AFS-200 in association with C-050.



FAR 121.445 and 8900.1 4-602 guidance provides that certain airports, due to characteristics such as surrounding terrain, obstructions, or complex approach or departure procedures may be designated as special airports requiring the PIC to hold special qualifications prior to landing or taking off from that airport.

An airport assessment aid is provided as part of the 8900.1 guidance to assist in determining if an airport qualifies as a Special PIC airport. When considering the assessment aid coupled with the methodology used for conducting an airport assessment, it is clear that KMMH meets the criteria threshold for listing as a special PIC Qualification airport.

Being nestled on the eastern slopes of the central High Sierra Mountains, KMMH possesses the following characteristics that have a direct effect on flight operations.

Examples below:

•         High terrain in the immediate vicinity

•         Limited maneuvering area

•         Significant unlighted terrain affecting night operations

•         Complex instrument procedures

•         Significant winds, turbulence and windshear

•         Unique communications and surveillance considerations

Meeting Discussions: FAA agrees and list will be updated. Should be completed soon - FAA has taken action to update the notice.

Intended Outcome:

Add Mammoth Yosemite; (KMMH), Mammoth Lakes Calif. To the Special Pilot-In-Command Qualification list maintained by AFS-200 in association with C-050.

Action Items:

In process

Deadline UNK



3b   .         C050: Special Pilot-in-command Qualification Airports (BAIR)


FAA Lead : Bob Davis, AFS-260

Industry Lead : TBD

Issue Statement:

Add Akureyri Airport, Iceland (IATA,AEY;ICAO BAIR) to the 14 CFR121.445 list.


This airport also has many of the attributes that would qualify it as a Special Pilot-in-Command Qualification airport. It is located on the Northern Icelandic coast. The airport is situated next to a river estuary with a north-south orientation (7874 ft.). There is steep terrain to the south. Bob Davis mentioned that the ILS may have as much as a five degree glideslope. The advantage of having a means of qualification for this airport is that it offers an alternative to Keflevik when that airport is affected by the occasional 40 mile an hour sea fog or volcanic ash inundation. During the last volcanic eruptions, due to favorable prevailing winds, Akureyri was unaffected. The downside is limited ramp space.

Meeting Discussions: This issue was not discussed at the July meeting. Deferred

Intended Outcome:

Add Akureyri, Iceland (BAIR) to the Special Pilot-In-Command Qualification list maintained by AFS-200 related to Ops Spec C-050.

Action Items:

Above proposal is in process.

Deadline UNK




4.       C081: Special Non 14 CFR Part 97 Instrument Approach or Departure Procedures


FAA Lead: Sara Dalton/Kel Christiansen, AFS-470

Industry Lead: Jim Winkleman, Alaska Airlines

Issue Statement:

Who is responsible for maintenance, upkeep and the costs associated with Special flight Procedures (sometimes referred to as “Public Specials”).


A public instrument flight procedure (IFP) is one that has been promulgated under 14 CFR Part 97. Often times Special instrument flight procedures that have been authorized for multiple users have been referred to as "Public Specials".   In actuality, these are not "public" procedures although some in the industry continue to refer to them as such.

The majority of those “Special” IFPs that have been authorized for multiple users are maintained by the Aeronautical Products Division of Mission Support Services, formerly known as AeroNav Services or the National Flight Procedures Office.

The Aeronautical Products Division enters into a reimbursable agreement to develop/maintain those Special IFPs used by a single operator. The issue concerning the appropriateness of seeking reimbursement (from operators) for Special IFPs that have been authorized for multiple users has been referred to Legal.

Meeting Discussions:

Still in evaluation: FAA gathering a single consolidated list of all approaches affected. No date set yet.

FAA still determining what FAA will pay for and what Industry is responsible for. Will GA operators have to share in the costs? What rule addresses the right for FAA to charge for services (8260.19??) (FAR 183 or 187??) No interpretation from FAA legal yet.

Intended Outcome:

Determine who is responsible for “Specials” or move them to the public domain.

Action Items: In process

Deadline           UNK






FAA Lead: Kel Christianson AFS-470

Industry Lead: Joe Devito

Issue Statement:

The certificate holder is authorized to conduct the instrument approach procedures other than ILS, MLS, or GPS landing system (GLS) utilizing a visibility and a decision altitude/(height) [DA(H)] equal to the published visibility and minimum descent altitude (MDA) using the aircraft and procedures as specified in this operations specification.


Based on near-term safety benefits of using a continuously defined vertical path to the runway, and a long-term goal of simplifying approach training and qualification standards, users have indicated their intent to begin additional use of VNAV capability for instrument approaches

Meeting Discussions:

There is a problem with subparagraph c of the final language in the Ops Spec and N 8900.183, Ops Spec/MSpec/LOA C073, Vertical Navigation (VNAV) Instrument Approach Procedures (IAP) Using Minimum Descent Altitude (MDA) as a Decision Altitude (DA)/Decision Height (DH):

c. Authorized Approaches. The certificate holder may fly all part 97 nonprecision straight-in IAPs listed as authorized in their C052, Table 1, columns 1 and 2 using an MDA as a DA/DH if the approach being flown meets one of the following requirements and its subcomponents:

(1) Serves a runway that has a published RNAV IAP (“RNAV” or “GPS” in title) with a published LNAV/VNAV DA/DH and—

(a) Has the exact published final approach course as the RNAV IAP.

(b) Has a published glideslope (GS) or vertical descent angle (VDA) coincident with or higher than the GS on the published RNAV IAP.

(c) Is selected from a certified database and displays a final approach Flight Path Angle (FPA) that matches the GS or VDA on the published IAP to be flown.

(2) Serves a runway that has a published ILS, MLS, LPV, or RNP AR IAP and—

(a) Has the exact published final approach course as the ILS, MLS, LPV, or RNP AR IAP.

(b) Has a published GS or VDA coincident with or higher than the GS on the published ILS, MLS, LPV, or RNP AR IAP.

(c) Is selected from a certified database and displays a final approach FPA that matches the GS or VDA on the published IAP to be flown.


Many FMS databases do not exactly match the charted Instrument Approach Procedure glideslope or final approach courses, depending on how the FMS is programmed. This is probably an issue that would be better addressed by the FAA-Industry CNS task force.


Industry representatives asked for delay in the mandatory implementation date of the new template until the issue of Ops Spec language could be resolved.

Intended Outcome:

Industry representatives asked for delay in the mandatory implementation date of the new template until the issue of Ops Spec language could be resolved. The mandatory revision date has been delayed until 2/28/2013. The previous template can now to moved from WebOPSS “Available” to “Workspace” for drafting carrier changes to the previous template .

Action Items: In process



6. A001 Issuance and Applicability


FAA Lead: Bob Davis

Industry Lead: Mike Keller

Issue statement:

The certificate holder is authorized to conduct flights under 14 CFR Part 91 for crewmember training, maintenance tests, ferrying, re-positioning, and the carriage of company officials using the applicable authorizations in these operations specifications, without obtaining a Letter of Authorization, provided the flights are not conducted for compensation or hire and no charge of any kind is made for the Conduct of the flights.


A Carrier had a flight diverted for mechanical issue. The passengers were off loaded and the aircraft was to be ferried to a major maintenance facility. The divert airport had no capability to off-load the cargo. American did not charge for the conveyance of the cargo. An inspector’s interpretation is that there was still a violation of maintenance ferry flight restrictions because a cargo fee rebate engenders good will with the customer and would likely generate future revenue.

Meeting Discussions:

Bob confirmed with FAA legal that under current regulatory guidance the cargo should have been removed (Legal is apparently unwilling to move on this). The question is can some Ops Spec language be written in such a way to allow this type of contingency? Group consensus was for industry to propose language for D084. It may be possible to have success if Industry creates language that not only meets the text of the regulation and the spirit of intent as published in the federal register for the 14 CFR 91 applicable paragraphs.

Intended Outcome:

See if a remedy to this situation is possible through exemptions or Ops Spec non-standard language

Status: In process



7. C300: Part 97 NDB, NDB/DME, VOR, and VOR/DME Instrument Approach Procedures Using
                          Substitute Means of Navigation



FAA Lead: John Swigart, AFS-470

Industry Lead: Jim Winkleman, Rich Yuknavich


Issue Statement:

Suitable NAVAID substitution authorizations are needed by operators in certain circumstances or areas of the world.



C300 was developed to provide standard methodology for authorizing NAVAID sub procedure for approach operations. The current template does not necessarily meet the needs of all operators or provide the latitude necessary for certain circumstances.

John Swiggart AFS-470 briefed that there are no plans to make any immediate changes to the Ops Spec, but AFS-470 would entertain submission of non-standard language for special cases. John suggested that carriers, especially those without Ops Spec C300 make maximum use of the provisions outlined in AC90-107 for RNAV substitution. Depending on the final analysis of the MITRE study AFS-470 may first allow use of C300 for alternate approaches


Meeting Discussions:

A study to access the safety risk of allowing use of RNAV approaches for alternate airport approach minimums was conducted for the FAA by MITRE Corporation. The initial report was found to be deficient and an addendum study was conducted. The final report should be delivered to HQ FAA around the end of July. Industry representatives expressed a desire to have the final report analysis made public so that industry experiences with GPS could be added to the MIITRE results.


Industry representatives raised the possibility of harmonizing U.S. alternate minimums policy with Canadian CARs:

3.14.1 Alternate Aerodrome Weather Minima Requirements

Authorized weather minima for alternate aerodromes are to be determined using the information presented in the tables below. The “Alternate Weather Minima Requirements” table presented in the CAP GEN (reproduced below) applies to all approach charts, except where use as an alternate is not authorized on the chart. The minima derived for an alternate aerodrome shall be consistent with aircraft performance, navigation-equipment limitations, functioning navigation aids, type of weather forecast and runway to be used.


Pilots can take credit for a GNSS approach at an alternate aerodrome, provided that the planned destination aerodrome is served by a functioning traditional approach aid; and the pilot verifies that the integrity, provided by RAIM or WAAS (wide area augmentation system), and that is required for a lateral navigation (LNAV) approach, is expected to be available at the planned alternate aerodrome at the expected time of arrival at the alternate, as explained in COM 3.16.12. Note that if credit is taken for a GNSS approach at an alternate aerodrome to fulfill the legal requirements for flight planning, no part of the approach at the destination may rely on GNSS. Otherwise, when determining alternate aerodrome weather minima requirements, the pilot shall only take credit for functioning traditional aids at that aerodrome.


If credit is being taken for a GNSS-based approach at the alternate, the published LNAV minima are the lowest landing limits for which credit may be taken when determining alternate weather minima requirements. No credit may be taken for lateral navigation / vertical navigation (LNAV/VNAV) or localizer performance with vertical guidance (LPV) minima.


Pilots may take credit for the use of GNSS in lieu of traditional ground-based NAVAIDs at a filed alternate aerodrome, as per COM 3.16.9 and COM 3.16.12.


Doug Snow, FEDEX Dispatch proposed allowing use of VFR weather minimums for alternate airports that only have GPS/GNSS approaches if there is an anticipated delay in final resolution of GPS use at alternate airports.


Intended Outcome:

Provide a mechanism to authorize use of NAVAID substitution or mitigation procedures that meet the needs of both Industry and FAA, especially for alternate airport minimums.


Status: Open/Monitor

Update from AFS-470, Jim Winkleman, Rich Yuknavich.



8a. B036/B054: Class II Navigation


FAA Lead : Madison Walton

Industry Lead: John Cowan


Issue Statement:

Both of these Ops Specs include the same provision in paragraph b. (4)

b. Special Limitations and Provisions . The certificate holder shall conduct all operations using multiple

LRNS in accordance with the following limitations and provisions:

(4) Prior to entering any airspace requiring the use of a long-range navigation system, the aircraft position

shall be accurately fixed using airways navigation facilities or ATC radar. After exiting this airspace, the

aircraft position shall be accurately fixed and the long-range navigation system error shall be determined

and logged in accordance with the operator's approved procedures.


Industry representatives contend that the requirement for deliberate fixing procedures have been made obsolescent by modern multi-sensor FMS navigation systems that use constant DME-DME or GPS and DME-DME fixing to update the FMS present position. Furthermore, industry contends that deliberate flyover position fixing or radar fixing is much less accurate than automatic position updating and may increase the possibility of position errors during position fixing if an unintentional position update occurs.


Intended Outcome:

Clarify the provision to specify that it is referring to non GPS equipped aircraft as follows:


b. (4) Prior to entering any airspace requiring the use of a non GPS based long-range navigation system, the aircraft position shall be accurately fixed using airways navigation facilities or ATC radar. After exiting this airspace, the aircraft position shall be accurately fixed and the long-range navigation system error shall be determined and logged in accordance with the operator's approved procedures.



b. (4) Prior to entering any airspace requiring the use of a non GPS based LRNS, the aircraft position shall be accurately fixed using airways navigation facilities or ATC radar. After exiting this airspace, the aircraft position shall be accurately fixed and the long-range navigation system error shall be determined and logged in accordance with the operator's approved procedures.

Meeting Discussions:

Some industry representatives expressed a desire to include multisensory DME-DME updating in the above verbiage and there seemed to be no FAA objections to this minor addition.


(4) Navigation Accuracy Checks

(a) Prior to entering any airspace requiring the use of an LRNS, for aircraft with GPS/GNSS or DME/DME automatic position updating the system must be confirmed to be functioning normally(no fault indications); for all other aircraft, the position shall be accurately fixed using airways navigation facilities or ATC radar.

(b) After exiting this airspace, the airplane position shall be accurately fixed and the LRNS error shall be determined and logged in accordance with the operator's approved procedures. An arrival gate position check satisfies this requirement. For aircraft with GPS/GNSS or DME/DME automatic position updating, no exit position fix is required unless there is an indication of FMS system malfunction.


Madison Walton presented draft Ops Spec B036/054 proposals.


Status: Paul Lepine will make available for industry review Notice 8900.B036.


8b. B036/B054: Class II Navigation and Oceanic Procedures


FAA Lead: Madison Walton

Industry Lead: John Cowan


Issue Statement:

While Ops Spec B036 includes no reference to plotting or adherence to AC 90-79, the “job aid” inappropriately requires the Inspector to ensure that the procedures included in the AC are used, thus causing differing expectations.



Where the FAA does not desire the operator to consider GPS as an acceptable airway navigation facility, the clarifier “ground based” is used. Several readers have incorrectly interpreted this provision with the same “ground based” mind set which has led to confusion when GPS equipped aircraft are concerned. Since a job aid for an Ops Spec should not contain provisions, limitations or requirements that are not also contained in the Ops Spec, the B036 job aid should be revised to match the Ops Spec:

  1. The principal operations inspector (POI) must ensure the operator’s LRN program incorporates the practices and procedures recommended in the most recent version of Advisory Circular (AC) 90-79, Recommended Practices and Procedures for the Use of Electronic Long-Range Navigation, or the operator has approved procedures equivalent to or exceeding those in AC 90-79 or other applicable ACs.

Intended Outcome:

Update the B036 Job Aid and eventually update AC 90-79:

The Principal Operations Inspector (POI) must ensure the operator’s LRN program incorporates practices and procedures that include crosschecking to identify potential navigational errors in sufficient time to prevent deviations. Advisory Circular (AC) 90-79, Recommended Practices and Procedures for Use of Electronic Long-Range Navigation, provides examples of such procedures but does not represent the only means of compliance.

Meeting Discussions:

John Cowan, the primary industry lead was not in attendance. Oceanic plotting procedures are being discussed in OSWG subgroup discussions.


Previously Per Mark Steinbicker

The FAA is moving forward with the navigation accuracy check issue, mindful of workload for the personnel involved. The main intent is that for whatever new guidance is created, there will be an emphasis on application of existing procedures regarding the use of GNSS/Sat-Nav for navigation (e.g., preflight/dispatch actions).


AFS-402 plans to start a revision of the 8900.1 in May that will address the OSA (now signed) and other SAO/Oceanic issues but don't have a revision to AC 91-70A scheduled. He does not view the AC language as a hindrance to moving forward with the alternate method and anticipates an AC revision once a number of other necessary changes are compiled (e.g., based upon updates to SAO airspace/procedures). The subject matter experts are fully engaged.


Status: Open


9.       B041 North Atlantic Operations with Two-Engine Airplanes Under Part 121


FAA Lead: Gordy Rother

Industry Lead: TBD


Issue Statement:

There is industry opinion that B041 needs to be revised greatly or actually archived.


The requirement to remain within 60 minutes of an adequate airport for non ETOPS two engine aircraft is a worldwide requirement, but yet we have no worldwide Ops Spec, only B041 for the North Atlantic.



The Ops Spec was originally developed to provide an enhance means of safely conducting non-ETOPS operations in the North Atlantic and to address the specifically challenging areas of Greenland etc. The Ops Spec adds weather minimums to the "adequate airports" outlined in 121.161. It also states the airport has to be one where you can land the aircraft safely with an engine failed. When the FAA discussed this with the AEG, their position is that the operator must evaluate the engine fail/go around case for the airports. This was further discussed with Boeing who agreed that "alternates for the purpose of ETOPS" must consider the engine fail case." Since B041 is an en route alternate like B342 without the higher weather provision this would fall into the same category. An engine failure is probably the reason you are diverting there in the first place.

The FAA is doing some historical research into this paragraph but may not yield anything other than the fact that this area has limited resources for the pilot. The requirement to have landing weather minimums can be onerous given the climate in Greenland and Iceland. The good thing is the vast majority of the aircraft meet the ETOPS requirements and these airports are rarely considered in that calculation and B041 is not a common operation.   What does not make sense to some is why this was never moved into the North Pacific/Russian airspace.

Intended Outcome:

To determine: Is the Ops Spec relevant to operations today?

If so, then expand the Ops Spec to encompass other equally challenging areas of operation.

If not, and there is an equivalent level of safety then develop a timeline to archive the Ops Spec.

Meeting Discussions:

Appropriately enough, Gordy Rother was attending a North Atlantic Operations conference and was not able to attend the OSWG meetings.


Open for discussion.



10. C63: IFR RNAV 1 Departure Procedures (DP) and Standard Terminal Arrivals (STAR)


FAA Lead: John Swigart, AFS-470

Industry Lead(s): Rich Yuknavich


Issue statement:

Development of RNAV DPs/STARs utilizing RNP 1.0 and RF legs on fast track.



The recent notice also announced the revision to all C063 templates. This is a non-mandatory revision. The current template will remain valid and will only need to be updated when one of the following occurs:

• The certificate holder/operator/program manager needs to make a change to the aircraft or systems on the template, or

• The certificate holder/operator/program manager applies for RNP 1 or TA authorization.

Meeting Discussions:

RNP SIDs & STARs will have to be listed in C081 for a period of time. Industry is seeking a way to document use of all of these procedures in a single way.


Rich Yuknavich suggests it might be helpful to read the C063 guidance in Order 8900.1, Vol. 3, Chap. 18, Sec 5 Change 188 (1/6/12) for an overview before referring to N8900.176.or the Advisory Circulars.


Intended Outcome:



Retain as discussion item for future feedback about RNP SID or STAR procedure and TA development.



11.   C055: Alternate Airport IFR Weather Minimums


FAA Lead: John Swigart, AFS-470

Industry Lead: Jim Winkleman, Andy Newcomer,


Issue Statement:

Unmonitored NAVAIDS are a problem for industry and may be having an effect on reliability of service, especially for longer haul operations.



Historically NAVAIDS have been monitored by FAA or entities designated by the FAA. As more responsibilities are being contracted to third parties, the ability to monitor essential NAVAIDS is no longer possible under certain circumstances. The increase in the number of unmonitored NAVAIDS is beginning to have a negative effect on providing reliable air transportation with loss of either certain alternate airport minimums or elimination of some alternate airport utilization.


In December 2011, a draft copy of the MITRE contractor study concerning feasibility and safety assessment of allowing alternate minimums based on GPS approaches was published. AFS-470 is reviewing the study. If it is determined that changes can be made to current policy, there will need to be harmonization between the different 14 CFR carrier types. Related guidance in the Instrument Procedures Manual and the AIM will also need to be updated. If GPS minimums are allowed, there is a possibility of two eligibility tiers for aircraft based on navigation system levels of fault detection and fault alerting. Similar RAIM prediction requirements as are in place for C300 may be required. (References TSO 196 for WAAS, TSO-129 for DME/DME updating.

Intended outcome:

Develop a solution that meets the needs of both Industry and FAA.

MITRE study to determine whether use of RNAV/GPS approaches at alternates affords an acceptable level of risk. A suggested interim mitigation strategy is issuance of alternative missed approach procedures whenever NAVAIDs go unmonitored.


Meeting Discussions:

Refer to Meeting Discussion for Item 7 Ops Spec C300


Doug Snow, FEDEX Dispatch proposed allowing use of VFR weather minimums for alternate airports that only have GPS/GNSS approaches if there is an anticipated delay in final resolution of GPS use at alternate airports.


Open: AFS-410 is looking at possibility of using RNAV approaches for alternate minimums.

Need list of unmonitored NAVAIDS to be sent to Coby Johnson.



12.   C067: Special Airport Authorizations, Provisions Limitations



Industry Lead(s): Jim Winkleman, Rich Yuknavich


Issue statement:

Concern that there two paragraphs (a & b) that address two different specific airport issues but a single table to list the airports.


a. The certificate holder is authorized to conduct operations into the specific airports listed in Table 1 for such things as:

(1) Airports that may require special aircraft performance charts and equipment or required special lighting for airports—flare pots, RBI, or required special navigation and communications equipment, etc.,

(2) Airports that require a curfew notation

(3) Airports with unpaved runways or runways constructed on frozen lakes and rivers

(4) For Flag or Supplemental destination airports that do not have an available alternate in

accordance with 14 CFR Section 121.621(a)(2) or 121.623(b) that are dispatched in accordance with

the required fuel reserves set forth in Section 121.641(b) or 121.645(c) as applicable, may be listed

along with any special provisions or limitations.

b. Uncertificated Airports.


A further complication is that many PIC special Qualification airports have issues over and above the issues that resulted in the designation as a Special Qualification airport. Many carriers make mention of the PIC S.Q. issues in Ops Spec C067 to avoid confusion when additional issues are addressed.


Intended Outcome:

Inspector Scott Stacy requests that the issue be addressed and to consider adding a second table. The result would allow for one table for each specific issue.

Meeting Discussions:

Multiple tables may not be necessary. Recent template reformatting provides more space for entry of information in the right column, “Special Provisions and Limitations and Special Flight Crewmember Training.


Status: Open with Closure Recommended



13.   D301: Aircraft Network Security Program (ANSP)


FAA Lead: Rochelle Brisco (AFS-360)

Industry lead: TBD


Issue Statement: The FAA is concerned about the cyber security vulnerabilities of avionics systems. This Ops Spec authorizes the certificate holder to operate e-Enabled aircraft that have a manufacturer's recommended network security program.


                  Avionics and passenger systems now similar to a Local Area Network (LAN).


                  Aircraft have the capability to reprogram flight critical avionics components wirelessly and via various data transfer mechanisms.


                  May result in cyber security vulnerabilities from intentional or unintentional corruption of data and/or systems critical to the safety and continued airworthiness of the airplane.

                  Credible examples of potential misuse include the potential for:

§                Malware to infect an aircraft system

§                An attacker to use onboard wireless to access aircraft system interfaces

§                Denial of service of wireless interfaces

§                Denial of service of safety critical systems

§                Misuse of personal devices that access aircraft systems

§                Misuse of off-board network connections to access aircraft system interfaces

                  Applies to aircraft operated under 14 CFR parts 121, 121/135, 125, and 129.


                  Necessary to verify that operators have the skills, tooling, and procedures in place to accomplish the requirements of the manufacturer’s aircraft security document.


                  Aircraft that require an ANSP include any aircraft produced or modified that requires the manufacturer to provide operator guidance documentation for FAA approval. The FAA requirement is in the form of Special Conditions.

§                Boeing provides this guidance in an ancillary document referred to as “Airplane Network Security Operator Guidance (ANSOG).” Airbus includes “Aircraft Information System Security” guidance in Part 6 of Aircraft Limitations Section (ALS) of the aircraft maintenance manual.

                  No longer a physical partition between avionics and passenger electronics.

                  Examples of e-Enabled aircraft: Boeing 747-800 and 787, Airbus A350 and A380, Bombardier CS100 and CS300


Background: FAA determined that manufacturers, carriers, and regulators were not paying enough attention to security issues in development and intended use of new systems. FAA observed that avionics evolution is away from hard-coded ROM circuit card hardware toward generic black boxes whose functions are defined by the software loaded into those boxes. The immediate concerns are with current E-enabled aircraft such as the 747-800 787 A350 and A380. However some future STC modifications may place current aircraft under Ops Spec D301 coverage. Carriers will be required to incorporate manufacturers’ security document procedures into carrier manuals. Currently, overall maintenance program manuals are accepted versus approved documents. Under Ops Spec 301 the subset of manuals applicable to avionics becomes approved publications. There are reporting requirements outlined in the draft Ops Spec.


Uplinked tailored arrival technology is not considered to fall under D301 guidelines.

The FAA intends to create guidelines for security provisions in the development and use of aircraft software interfaces. Encourage participation by air carrier IT and avionics departments.

Special Committee 216 has been formed. Coordinating with EUROCAE WG-72 Group.

Draft Ops Sec D301, Aircraft Network Security System, and accompanying Notice is posted on http://www.faa.gov/aircraft/draft_docs/opspecs/. The comment period officially ended in May 2011.


Intended Outcome:

Ops Spec that will require carriers to incorporate manufacturers’ security document procedures into carrier manuals. Currently, overall maintenance program manuals are accepted versus approved documents. Under Ops Spec 301 the subset of manuals applicable to avionics becomes approved publications. Reporting requirements are outlined in the draft Ops Spec.

Meeting Discussions:

Rochelle announced that 8900.1 guidance and Ops Spec Template approval was signed 31 May 2012.

Some industry representatives asked why, instead of an Ops Spec directed toward operators, revisions to 14CFRPart 25 were not made to place the emphasis for compliance on the aircraft manufacturers.

As with database integrity, carriers are tasked to coordinate compliance with manufacturers who have a stack in assisting carrier compliance. Ops Spec is necessary for FAA to ensure that manufacturers provide the tools to operator for management of potentially vulnerable aircraft systems.


Due to unique conditions that certain 135 operators are under, they may need to coordinate directly with Chelle, AFS-330, (or Tim Shaner?) to work out specific issues (coordination early will probably be better than later).

4. This Ops Spec applies to any operator who has aircraft equipped with internet connectable systems.

Status: Open. To be retained as an open item



14. D081: Parts Pool Agreement Authorization




Industry Lead: Mike Keller, American


Issue Statement:

Does D081 allow for “parts borrowing” or not?


Can the parts supplier DBA “AJ Walters” be added to the Ops Spec if possible to be able to borrow parts from them internationally? AJ Walters is a parts supplier and not an airline which seems to be the issue. AJ Walters is an associate member of the IATP as well. Some other airlines may be utilizing AJ Walters, but under what authority?

If a supplier such as “AJ Walters” is not a certificated entity then pooling under D081 would not apply.


Intended Outcome:

Determine if parts borrowing fall under the authority of parts pooling?

Meeting Discussions:

FAA is conducting research to determine if AJ Walters may be added to Ops Spec D081. AFS-330 said that it is difficult to audit a “supplier” like “A.J. Walters.”


Status: Ongoing FAA research



15.   D084 Special Flight Permit with Continuous Authorization to Conduct Ferry Flights


FAA Lead: Mark Lopez AFS-330

Industry Lead: Tom Taylor/Doug Snow, FedEx Express


Issue Statement:

1.            Ops Spec D084 item b. does not provide wording to allow ferrying an aircraft to storage or to a place where the aircraft will be donated, scrapped, sold, etc.

2.            Ops Spec D084 item d. does not provide wording to allow ferrying to storage on the way to a repair facility to have an expired AD complied with or to a place where the aircraft will be donated, scrapped, sold, etc.



1.            14 CFR 21.197 Special flight permits, item (c) allows certificate holders with a D084 Ops Spec to issue a Special Flight Permit for the purpose of flying aircraft to a base where maintenance or alterations are to be performed. Item (a) (1) of the same CFR allows for Special Flight Permits, outside of the D084 Ops Spec, to be issued to a base where repairs, alterations, or maintenance are to be performed or to a point of storage. Within the D084 Ops Spec and item (c) of the CFR, the words repair and storage are left out. It could be argued that maintenance and repair are one in the same therefore the word repair was left out, therefore it could also be argued that the intent of the abbreviated verbiage in Ops Spec D084 and item (c) of the CFR is not intended to prevent moving an aircraft to storage on its way to a maintenance facility to have the required work accomplished when a maintenance slot becomes available.

2.            14 CFR 39.23 Airworthiness Directives, starts out with a question – [May I fly my aircraft to a repair facility to do the work required by an airworthiness directive?]. The answer is yes, but it also states the aircraft can be flown to a repair facility to do the work required by an Airworthiness Directive. Like stated above, there is no mention of flying the aircraft to a place of storage while awaiting a slot at a maintenance facility where the AD can be complied with.

Intended Outcome:

FEDEX Express is seeking an Ops Spec provision or CFR exemption relief.

Is it the FAA’s intent that a certificate holder with a D084 Ops Spec cannot ferry an aircraft to storage for any reason? Is it also the intent that no one, certificate holder or FAA, can issue a Special Flight Permit, with an expired AD, to a storage facility while awaiting a slot at a maintenance facility where the AD can be complied with or to a place where the aircraft will be donated, scrapped, sold, etc.?


- Need an FAA legal interpretation of items 1 and 2 above.

- If a FAA legal interpretation allows a certificate holder to ferry an aircraft to storage in both cases above, we would like to see the D084 Ops Spec revised with language addressing the issue of flying to storage in both cases as well as flying to a place where the aircraft will be donated, scrapped, sold, etc.

- If item 1 and 2 above does not allow the aircraft to be flown to storage, or flown to a place where it will donated, scrapped, sold, etc. we would like to see an exemption issued that allows it?

Meeting Discussions:

FAA reported that the rules do not allow for this type of operations due to compliance time over-runs. Possible to get an AMOC to move the aircraft from out of storage to a repair facility.

1. This may have to be dealt with on a case-by-case basis due to the number of variables.

2. FAA to check into moving an non-airworthy aircraft to a place other than a maintenance or repair facility.


Status: Ongoing research



16.   D095. Minimum Equipment List (MEL) Authorizations



Industry Lead: Mike Keller/Rich Yuknavich


Issue Statement:

Ops Spec D095 Maximum times between deferral and repair are not the same as stated in MMEL Policy letter 25 January 2012. The Ops Spec language for Category A items does not specifically state that the day the malfunction is recorded is excluded in counting maximum numbers of days as does the MMEL Policy Letter and as do Ops Spec D095 paragraphs b(2), (3) and (4):




D095 Verbiage:

b. Maximum Times Between Deferral and Repair. Except as provided in subparagraph d, the

      certificate holder shall have items repaired within the time intervals specified for the categories of

      items listed below:

(1)    Category A. Items in this category shall be repaired within the time interval specified in the

(2)    remarks column of the certificate holder's approved MEL.


MMEL Policy Letter Revision 17 20Jan2011:

22. Repair Intervals: All users of an MEL approved under 14 CFR 121, 125, 129 and 135 must effect

repairs of inoperative systems or components, deferred in accordance with the MEL, at or prior to the

repair times established by the following letter designators. 14 CFR 91 MEL users do not need to

comply with the repair categories, but shall comply with any provisos defining a repair interval (flights,

flight legs, cycles, hours, etc). The letter designators are inserted adjacent to Column 2.


Category A. Items in this category shall be repaired within the time interval specified in the remarks

column of the operator's approved MEL. For time intervals specified in “calendar days” or "flight days,"

the day the malfunction was recorded in the aircraft maintenance record/logbook is excluded. For all

other time intervals (flights, flight legs, cycles, hours, etc), repair tracking begins at the point when the

malfunction is deferred in accordance with the operator's approved MEL.


Intended Outcome:

Change Ops Spec D095 Paragraph b(1) verbiage and in the interim specifically address the Category A disparity in a revised MMEL Policy Letter...

Meeting Discussions:

Update given by AFS-240

Briefed new Ops Spec language that was resulted by the MMEL Policy Letter 25. New Ops Spec template adds language. New draft should be available soon (Six months??) Guidance is drafted and due to go through the coordination process. Some duplicate language has been removed. The term “maximum” has been removed from the template to take away the ambiguity that it introduced. Each repair category may be extended one time. A one line sentence may be added telling operators they may request a second extension through the POI. If another extension is needed, the POI may issue a new extension for as long at deemed appropriate (POI is given this authority through the guidance documents). The revision may be issued as a non-mandatory Ops Spec change in order to allow the new template to be available sooner than when the new guidance is available.

Status: Open, monitor Updates.






17.   WebOPSS Update


Paul Lepine provided a WebOPSS update. For a more detailed listing sign onto WebOPSS and go to Tools/ Release Notes or Reports.

• System updates were conducted in last couple weeks. Some problems resulted from contractors conducting hot fixes, last update conducted during business hours causing many problems.

• Effective date is now out of the document and in the FAA digital signature block.

• Carriers can now enter revision notes.

• There are new reports available, an EXCEL compatible, sortable file, ICAO reports.

• A999 available in ICAO format

• Fleet specific Ops Specs in ICAO format available

• Contact Monica Grusche (Monica.grusche@faa.gov ) directly regarding any ICAO report errors.

• FAA soliciting info on any report errors so the system can be fixed if necessary



18.   S400 CAST Safety Enhancements


S400: CAST Safety Enhancements

FAA Lead: Bob Davis

Industry Leads: Monty Montgomery, United; Rich Yuknavich, American; Mike Davis, U.S. Airways.


Issue Statement:

The FAA has made a financial commitment to CAST, the Commercial Aviation Safety Team program and oversight agencies would like a means of gauging the overall acceptance and success of CAST,



Bob Davis.

S400 is not an Ops Spec. It is a document or perhaps multiple “S”-XXX documents to anonymously track carrier adoption of the voluntary Safety Enhancement recommendations of the Commercial Aviation Safety Team or CAST composed of FAA/Military/Manufacturers/Unions/Airline Industry/Trade Groups. The WebOPSS system is being used to leverage the capabilities of the system.


Meeting Discussions:

Phase I Beta testing has been underway with U.S. Airways and United. American and American Eagle Airlines will participate in Phase II testing. Only three of the currently published 75 SEs are being used for Beat testing, two concerning Ops and one concerning maintenance.


Bob Davis Update. Latest program enhancement is in beta testing on contractor servers. Best recommendation form testing, split the template into carrier functional areas or into individual templates for each CAST item of which there are currently 79.


Bob mentioned that S400 can be partitioned off from a carriers normal Ops Specs to prevent those with S400 access from accessing A,B,C,D, and E paragraphs.


Intended Outcome: Identify problem areas during Beta testing.


Action Items:

Testing in process



19.   ICAO Registry of AOCs


FAA Lead : Danuta Pronczuk (AFS-52) for Part 129,

Industry Lead : Henry Defalque, International Civil Aviation Organization, ICAO


Issue Statement

ICAO is developing a database to catalogue carrier Air Operator Certificates, home country certificating authority authorizations, and aircraft inventories.



Tentative Timetable

Late June – Pre-final Software developed
Late June until mid-July – CAUC (Civil Aviation University of China)

        Studentsto do internal beta-testing and simulate simultaneous data entry.

Late July – Present the final product to Nancy Graham/ICAO
August – CAUC to come to Montreal to present the final Product
                          Invite Canada for 1st Beta-Testing at the same time (TC – Transport Canada- is onboard)
                            Other states willing to participate: Australia, Singapore at this time.
Until end of 2011 – Beta-testing with different selected States

The aircraft information DB is operational since November 2010, and we hope that the Intl Registry of AOC will be operational at the end of 2011 or Q1 2012. The Civil Aviation University of China will install it on our server by mid-November... then it is internal testing and then testing by a few States (Australia, Canada, Singapore, UAE, and hopefully a European State). (Update from Henry D., provided on 10/01/2011)


The developers are scheduled to deliver the product in November. ICAO will then install it on its servers and open it up for beta testing to the States that have volunteered for this process. Barring any major issues, it should go live as planned. (Update from Tom Mistos, ICAO, 10-13-11).


The ICAO aircraft information database that will be linked to the AOC database is operational and contains aircraft from 22 States already with more pending (Update from Henry, July 2011). The aircraft registry application is slowly getting more input from States. There had been two issues holding ICAO back, a bug/issue with the Excel template upload facility and the IRCA update process (those States that will be sending their input via IRCA need to sign a release form with IRCA giving them permission to send us the State’s data). The first issue has been resolved; however IRCA is still waiting for permission from many States. (Update from Tom

Mistos, ICAO, 10-13-11)


Meeting Discussion.

Related International Issues from Mike Frank, AFS-52, FAA Part 129 CoChairman.

• ICAO AOC in beta testing and progressing, albeit slowly.

•New contact/liaison at ICAO, Mr. Hong Fen Sow.


Status : Open, Expect update at October 2012 OSWG Joint/International Session.



20.   EASA Third Country Operators


FAA Lead: John Masters, AFS-51, Darcy Reed, AFS-52

Industry Leads: Default Brian Miles Part 129 Chairman/Emirates Airlines.


Issue Statement:

Status Report on EASA intention to implement an assessment requirement for all Third Country Operators (for example: United, FedEx, UPS, Emirates, China Southern Airlines, ANA, Quantas,

(Non-European Union member commercial carriers.)



Presented by EASA representative, Arthur Beckland, a Dutch attorney who has been with EASA for six years, currently with the EASA rulemaking directorate.


The proposal for one authorization for operations in the EU, one assessment methodology, (a validation process that aims at verifying the reliability of the originally certified information), was first promulgated in April of 2011.

It is still in the prepatory process for eventual submission to the European Parliament for ratification. The target date for that is estimated to be towards the end of 2013 or early 2014. Until then individual country national rules and ICAO rules apply. After implementation, if any aspect of operations is not covered by ICAO standards then EASA standards will apply. After ratification, there will need to be a period of harmonization with current bilateral agreements between EU and other non-EU countries.

There may be some bilateral agreements between the EU and certain third countries (for example the US and the EU), with both parties agreeing to accept the others authorizations with no added assessments necessary.


Ramp inspection will continue to be performed by national aviation officials but they should use EASA checklist criteria, and not country specific audit criteria. However there is no guarantee that individual countries will not use their own inspection criteria instead of using the EASA standards.


For more detailed information and status updates, Arthur recommended the following EASA website:


Meeting Discussion.

Update from Mike Frank, AFS-52, FAA Part 129 CoChairman.


Bilateral agreement provisions being discussed at the European Union council. Methodology is issue by issue discussion basis. Current topic is pilot licensing provisions.


Intended Outcome: update/educate, clarify rulemaking changes, and answer questions relating to EASA third country operators.


Status : Expect a detailed update at the upcoming Joint OSWG meeting on 17-18 October 12.


21. A025: Electronic Record Keeping Systems


FAA Lead : Theo Kessaris AFS-260

Industry Lead : Casey Seabright, Jim Winkelman


Issue Statement:

A025 has become a dumping ground for many authorizations that may not be appropriate for this paragraph or may be appropriate but are listed individually versus categorically. Many CMOs are requiring individual listing of each electronic manual instead of listing categories of manuals (e.g. Aircraft Flight Crew Operating Manuals; Maintenance manuals, engineering reference guides; AQP Training Documents, Dispatch Procedures Manuals etc.) Industry would like to form a subgroup to help write the new Ops Spec and requests a very generic high level approach to recording recordkeeping since new technology virtually requires electronic recordkeeping for many applications. The technology, stability, and reliability are no longer a new approach and should become accepted (at some level) as the norm.



An audit of operator’s A025 show significant variability in the items placed in this paragraph.


Intended Outcome:

Transform A025 from being a dumping ground and keep it only as a depository for primarily electronic record keeping plus an optional storehouse for electronic signatures and electronic manuals.

Amend A025 to include tables for specific approvals such as flight planning systems, training records repositories, and categories of electronic/digital manuals.


Meeting Discussion.

Theo Kessaris voiced concern that there are no resources on the FAA side to work the issue. She solicited help from industry if there is a desire to make progress on this project. Industry representatives seemed amenable to forming a sub group to draft proposed changes to the Ops Spec Template, 8900.1 guidance and possibly a revision to 120-78 1 “Acceptance and Use of Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manuals”


Status : Open, Volunteer participants solicited. Contact Casey Seabright.



22. A010: Aviation Weather


FAA Leads : Theo Kessaris, AFS-260 – Leo Hollis, AFS-220

Industry Lead : Casey Seabright, Delta


Issue Statement:

This Ops Spec/MSpec/LOA has been revised to follow the regulatory requirements of 14 CFR parts 91, Subpart K, 121, 125 and 135. A table has been added for Adverse Weather Reporting and Forecast systems, and the QICP table has been removed due to lack of regulatory requirement. Guidance in 8900.1 Volume 3 chapters 18, 25 and 26 has been updated as well. The Ops Spec /LOA is no longer mandatory for part 125 certificate holders, and part 125 Letter of Deviation Authority Holders



As of the last meeting in April 2012, the draft guidance was posted to the FAA draft documents website and to the OSWG (NAME WEBSITE) to allow for public comment. In addition, the documents went through formal internal FAA coordination. Both the public and FAA comment periods have closed and. The FAA received only one comment from industry which was in the form of a question regarding the removal of the QICP table from the Ops Spec. FAA internal comments are collected and organized by an internal support organization and then sent to AFS-200.


Meeting Discussions:


Comment period is closed. Rewriting should be complete early August. Once that is accomplished, the documents will be reformatted one more time and then submitted to AFS-1 for final signature and publication. The estimated publication date is probably sometime toward the end of September or beginning of October.

Theo stressed that the FAA does not approve a weather source but rather approves a carrier to use a weather source based on that carriers’ adequacy of training, descriptions of available reports, coverage area, etc.


Intended Outcome :

Standardized Ops Specs authorizations for certificate holders conducting 91K, 121, and/or 135 operations that comply with the regulatory requirements of 91.1039, 121.101, 121.119, and 135.213, as applicable. ..


Action Items:

Final actions by FAA; certification efforts by carriers.

Comment period is closed



23. B343: Fuel Reserves for Flag and Supplemental Operations


FAA Lead: Gordy Rother, MSP-FSDO, Leo Hollis, AFS-220, Dave Burnham, UAL CMO/ Steve Moates AFS-220

Industry Lead(s): Steve Kuhar, Casey Seabright, Rich Yuknavich


Issue Statement:

Numerous carriers want to be issued this Ops Spec which allows as low as five percent enroute reserves for that percentage of the total time required to fly from the airport of departure to, and land at, the airport to which it was released. Currently only two Part 121 operators, American and United have this Ops Spec.


Many International carriers are required to plan for less fuel reserves percentages than U.S. carriers. Many foreign carriers are allowed to use three percent reserves. This has puts U.S. carriers at an operating cost disadvantage, even though the FAA-required .ten percent reserves is only computed on those enroute flight segments that are in Class II airspace. Long flights over Class II airspace experience the biggest reserve fuel advantage. A little over ten years ago, the FAA began to level the playing field by granting, use of five percent fuel reserves to carriers that could prove their flight planning and weather prediction capabilities still provided adequate safety margins. American, United and Continental were granted B343 approval.


Authorization for additional carriers was halted following Congressional interest in one or two widely publicized minimum fuel declarations. However, the long term record of both American and United Airlines is very positive. For example, since May of 2004, American Airliners has flown 767,257 flights using B343 five percent planning parameters and has had only 104 of those flights burn into enroute fuel reserves. Most of these “Burn-Ins” were only a few minutes of fuel, but are reported none the less. Further approvals were also denied based on a planning reliability standard formulated by MITRE that counted fuel percentage of under-burn in the same category as over-burn. (In the case of FEDEX, over-burns this was due to due to contingency added fuel to account for frequent MD-11 tail fuel transfer failure to transfer. When transfers did occur, fuel consumption was much less than planned.)


More recently, further approvals are being delayed in anticipation of ICAO publication of international fuel reserve guidelines. There is a desire to ensure that U.S. policies harmonize with ICAO standards. FAA is working toward a Performance Based fuel reserves model similar to the draft ICAO Annex 6. FAA has requested that carriers review and comment on Annex 6 (draft) through IATA or ATA. Once the new Annex 6 is settles/issued, the theory is that B343 should be resurrected. A new FAA Advisory Circular is being drafted by the FAA.


Meeting Discussions:

The majority of the industry believes that the FAA should not have issued the B343 authorization to just a few carriers, but instead to all eligible. If more carriers were issued B343 a much larger performance database would have been accumulated. FAA contends that any operator may still apply for issuance, and if the requirements are satisfied, will eventually be issued. The problem is that, in the interim the Ops Spec disparity exists.

Intended Outcome:

PBM Fuel Reserves availability for US carriers sooner than later.


Status: New AC being written to harmonize with ICAO

Industry SMEs should volunteer to participate in guidance drafting/review.



24. A029 Aircraft Interchange Agreement for Part 121


FAA Lead: Craig Botko (AFS-200) for Part 135; Larry Buehler for part 121

Industry Lead : Rich Carpenter


Issue Statement:

Definition of Primary operator is not correct.



Ops Spec A029 authorizes part 121 certificate holders to use aircraft interchange agreements with other operators.

Meeting Discussions:

Correction in process, getting close to completion.


Intended Outcome:

Correction to definition of primary operator, and the addition of aircraft serial number to the Part 121 template


Status: Open



25. A003/C091 Airplane Authorization/Operational Requirements Airplane Design

                                                        Group VI (ADG-VI) Airplanes.


FAA Lead: Jerry Ostronic (Part121) Danuta Pronczuk and David Henthorn (Part 129)

Industry Lead: Andy Newcomer


Issue Statement:

It is necessary for carriers to analyze and coordinate with airports prior to operating Group VI aircraft into group V airports, specifically the B747-8 and the A-380.



Ops Spec C091 is required for anyone operating an A380. To date, only foreign air carriers were operating the A380. Foreign air carriers are already operating the B-747-8, Bob added that although no U.S. operator has a need for it currently; AFS-200 expects that to change in the future and as such will be adding this template to the Part 121 data base of available Ops Specs.

In the last Joint OSWG meeting, Danuta briefly reviewed the background on C091/the study of the group VI aircraft, (A-380 and B-747-8), operating into group V airports, issues surrounding group VI aircraft operating into group V airports, specifically the B-747-8 and the A-380. The limitations language has been agreed upon by both AFS-050 and AFS-200. After many hours of review, both divisions have agreed to keep the limitations on group VI aircraft operations into group V airports in Ops Spec C091. The existing limitations for the A-380 have been rewritten into plain language, and the B-747-8 limitations language will be added. A revised draft Ops Spec C091 is expected to be posted in the next few weeks. Limitations are based on the results of a study that was conducted – can the A-380, and B-747-8 safety operate on group V airports and under what conditions.

Meeting Discussions:

Ops Spec C091 is required for anyone operating an Airbus A380, (currently in the Part 129 data base of available Ops Specs), and once the draft is rolled out it will also be required to be issued to anyone operating the B747-8.


Status: Open. Standby for review of draft documents



26.   C054: Special Limitations and Provisions for Instrument Approach Procedures and

                                  IFR Landing Minimums


FAA Lead: Bryant Welch AFS-410

Industry Lead : Monty Montgomery


Issue Statement:

C054 needs to be more specific in its reference to “the landing field length specified for the destination airport by the appropriate Sections of the CFR”.



Many readers are unsure of what specific section of the CFR is being referred to, which leads to confusion. Jackson Seltzer (United) recommended standardization between C054 and other Ops Specs governing approach criteria, such as C060. Suggestion by Bob Davis was for coordination with industry and participation by Bryant Welch, Gordy Rother and Jerry Ostronic


Coby Johnson pledged support for harmonization guidance among Ops Specs C054, C059, and C060


Intended Outcome:

Industry proposed draft language for Ops Spec Paragraphs and applicable guidance adding an appropriate reference (121.195b) as shown below.


(2) A pilot-in-command of a turbojet airplane shall not begin an instrument approach procedure when the visibility conditions are reported to be less than ¾ statute mile or RVR 4000, unless the following conditions exist:

(a) Fifteen percent additional runway length is available over the landing field length specified for the destination airport by (14 CFR) § 121.195(b).


UPS believes the language in b (2) (a) is still a problem for when the landing data as required by 14 CFR 121.195(b) should be applied. UPS interprets the language, as it is currently written in section b, Limitation on the Use of Landing Minimums for Turbojet Airplanes, sub-section (2), line (a), that prior to approach, the PIC must apply the 115 percent of the runway field length as defined by 14 CFR part 121.195(b).  
UPS recommends that the language that is currently in the draft of C060 Category III Instrument Approach and Landing Operations, section c, Required Field Length and Special Operational Equipment and Limitations, be used as a model for this paragraph. This clarifies exactly when the 115 percent is to be applied and when the AFM limitations should be applied (with operational procedures and consideration to aircraft equipment status).


Meeting Discussions:

Draft Ops Spec C054 has been posted for comment. Bryant Welch was not available.


Status : Open



27.   C051: Terminal Instrument Procedures


FAA Lead: Chris Hope

Industry Lead: Andy Newcomer


Issue Statement:

Update language in C051 due to the term “EU-OPS” replacing “JAR-OPS” effective July 16, 2011



As per Commission Regulation (EC) No 859/2008 of August 20, 2008. See Official Journal of the European Union, September 9, 2008.

AFS 410 mentioned that a revision to this Ops Spec language is needed to update terminology JAR Ops/PANS-OPS to EU-OPS.


As a side note, 051 may be combined with C052 in the future.


Intended Outcome:

Replace references to JAR-OPS with EU-OPS.


Meeting Discussions:

Per Industry Lead Andy Newcomer: Through discussions with the FAA, some thought should be given to removing C051 as the paragraph may not even be required anymore. If it is, the replacing JAR-Ops with EU-Ops will be no problem. The FAA may consider expanding it to include MIPS (Military Instrument Procedure Standard) and some langue to include “Any approach procedure approved by AFS-400.”


Status: Open, corrections should be published soon.



28.   A027 Land and Hold Short Operations (LAHSO)


FAA Lead: Steve Moates, AFS 220

Industry Lead : Steve Kuhar


Issue Statement: Ops Spec and 8900.1 language are inconsistent.


Background : Inconsistent or conflicting language is inviting confusion.

Example: 8900 says “LAHSO is prohibited on contaminated runways”; however, the Op Spec says “LAHSO on wet runways is prohibited”. There’s a discrepancy in the windshear guidance also under LAHSO.


Intended Outcome:

Requesting clarification regarding this topic.


Meeting Discussions:

Correction of text in process


Status : Open



29.   AXX. Utilization of a Weather Support for Deicing Decision Making (WSDDM) System


FAA Lead: Possible: Charles (Chuck) J Enders, Craig Botko, Warren Underwood, James (Jim) Riley

Industry Lead: Andy Newcomer, UPS


Issue Statement:

The accumulation of ice on aircraft prior to take off has long been recognized as one of the most significant safety hazards affecting the aviation industry today. As little as 0.08 mm of ice on a wing surface can increase drag and reduce airplane lift by 25%. Acutely aware of the impacts these icing hazards can have on aviation, the Federal Aviation Administration (FAA) began supporting ground de–icing research at the National Center for Atmospheric Research (NCAR)*


To further the use of these systems the FAA and US Air Carriers should develop a means of authorization to use these systems where available. WSDDM system



The National Center for Atmospheric Research (NCAR) has been working with the FAA, airlines, and airports focused on developing two new systems in support of Ground Deicing operations. The Liquid Water Equivalent (LWE) system combines a Hotplate and GEONOR snow gauge, a Vaisala PWD–22 precipitation type sensor, a Campbell freezing rain sensor, a Vaisala WXT wind, temperature, and humidity sensor, and a Decagon Leaf Wetness Sensor to estimate a real–time liquid water equivalent precipitation rate. This rate is a critical component of the Checktime System, a UCAR patented technology for aircraft ground deicing operations, that determines when deicing/anti-icing fluids applied to aircraft are close to failure based on temperature measurements and precipitation rates that are updated every minute from the LWE system. Checktime is aircraft independent and only requires the end user to know the time that the aircraft was deiced.

Liquid Water Equivalent: Definition:

The liquid content of solid precipitation that has accumulated on the ground (snow depth). The accumulation may consist of snow, ice formed by freezing precipitation, freezing liquid precipitation, or ice formed by the refreezing of melted snow.


Intended Outcome:

Develop a non-standard ops spec which allows for use of these devices by interested industry participants as requested/desired by both FAA and Industry to demonstrate the system under an equivalent level of safety.


Meeting Discussions:

FAA is working this aggressively. Current work will not affect this year’s deicing policies

FAA will not be certifying deicing providers but rather authorize an operator to utilize those providers.


Status: Open for discussion.



30.   C077: Terminal Visual Flight Rules, Limitations and Provisions


FAA Lead: Theodora Kessaris, AFS-260

Industry Lead: Steve Bush


Issue Statement:

There is an apparent conflict between the Controller 7110.65 handbook guidance and Ops Spec guidance provided in C-077 regarding takeoff and climb on an IFR flight plan with a VFR/VMC restriction for 121 operations.



Ops Spec C077 paragraph “e” allows for an IFR departure with a VMC takeoff and climb to a specified point provided the requirements in paragraph “f” can be satisfied. The Controller handbook, 7110.65 section 7-1-2 also provides for this same type of IFR clearance, however, uses the term “VFR” instead of “VMC”.


This incongruence of terms used in the Ops Spec and Controller’s handbook has contributed to misunderstandings, differences in expectations between the flight crews and controllers and has contributed to avoidable delays in takeoff from uncontrolled airports.


Intended Outcome:

Change the term “VMC” found in paragraph “e” of Ops Spec C077 to “VFR” in order to be aligned with the term used in the Controller’s handbook.


Meeting Discussions:

Bob Davis AFS-200/260 stated that this issue has been raised in the past and the ATC folks are unwilling to change their handbook. If any change is to take place it will likely need to be in the Ops Spec template and associated guidance.


One suggested solution was to call attention to the expected ATC terminology in the operator guidance.


Status: Open


31.   Closing Remarks


Bob Davis, AFS-200/260

Thanks to those Industry and FAA officials who participated.


Rich Yuknavich, Industry Vice Chair

Make reservations now for the October 16-17 meeting sessions. Rates are cheaper now, and Washington D.C. hotels tend to start filling up as the fall election gets closer.